In short
Of the UK-authorised banks we checked, six publish a safeguarding account offer for payment and e-money institutions: ClearBank, Griffin, LHV Bank, The Bank of London, Starling (Banking Services) and the UK branch of Banking Circle. Barclays and Crown Agents Bank set out eligibility criteria for payment firms without a product page. The large high-street banks publish nothing for this market. The FCA says in PS25/12 that payment firms currently have difficulty getting these accounts, and the Electronic Money Association told the Bank of England that the number of banks with an appetite for them is limited.
Key takeaways
- A safeguarding account must sit with a bank authorised to accept deposits in the UK, or an approved foreign credit institution, and never with a company in the same group or with another e-money institution (Payment Services Regulations 2017, regulation 23; CASS 15 from 7 May 2026).
- Six UK-authorised institutions publish a safeguarding offer: ClearBank (no minimum volumes, 12 currencies), Griffin (dedicated or pooled accounts, API onboarding), LHV Bank (GBP and EUR, instant virtual IBANs), The Bank of London (deposits held at the Bank of England), Starling Banking Services (client money accounts, API) and Banking Circle's UK branch.
- No UK bank publishes its fees, minimum balances or interest rate for safeguarding accounts; Barclays says it applies minimum revenue thresholds and requires an independently reviewed financial crime report before onboarding.
- The banks named by payment firms in their own safeguarding disclosures include J.P. Morgan, Citibank, Deutsche Bank, Bank of America and Barclays (Wise), and NatWest (MuchBetter), none of which publishes a product page.
- The FCA recorded in CP24/20 that some payment firms continue to experience difficulties accessing safeguarding accounts, and in PS25/12 that access problems could potentially cause firms to exit the market; it has kept the diversification rules unchanged.
- From 7 May 2026 the bank relationship carries more weight, not less: CASS 15 keeps the acknowledgement letter, annual due diligence on the bank and a notification to the FCA if the bank closes the account.
What the rules require of the bank
A payment institution or e-money institution that holds customer money overnight must either place it in a safeguarding account at a credit institution or cover it with insurance. Regulation 23 of the Payment Services Regulations 2017 (and regulation 20 of the Electronic Money Regulations 2011) requires the account to be with a person authorised in the UK to accept deposits, or an approved foreign credit institution supervised in an OECD country. The account cannot be with a company in the firm's own group and cannot be with another e-money institution: an e-money account at a fintech is not a safeguarding account.
The bank must acknowledge in writing that the account holds customer funds and that it has no right of set-off against them. From 7 May 2026 these duties sit in CASS 15 under PS25/12: an acknowledgement letter in the FCA's form, due diligence on the bank before opening the account and at least annually, diversification where the sums justify it, and a notification to the FCA if the bank gives notice to close the account. The FCA consulted in 2024 on requiring customer money to be received directly into a designated safeguarding account under a statutory trust, and in PS25/12 put that part back for further consultation because of the access problems described below.
This page lists what banks publish, what payment firms say about the banks they use, and what the regulator and the industry bodies have said about getting an account. It does not list fees, minimums or interest, because no UK bank publishes them. For the rules in full see the PS25/12 safeguarding guide and the acknowledgement letter guide.
Banks that publish a safeguarding offer
Authorised status is from the Bank of England's list of banks (October 2026). Conditions are as published on each bank's own pages; where a bank says nothing about a point, the entry says so.
- ClearBank (UK bank). Offers: Safeguarding accounts for EMIs and PIs; CASS 7 client money accounts; segregated customer accounts with up to 6 million virtual accounts. Published conditions: Only firms with the corresponding regulatory permissions; no minimum volume requirements; safeguarding acknowledgement letter on request; 12 currencies (GBP, USD, EUR, PLN, CZK, HUF, SEK, DKK, NOK, CHF, RON, CAD); API first; FSCS eligible balances protected; interest and fees not published. Named payment firm clients: PayDo (2024); Fiat Republic through ClearBank Europe (2026). Source: Accounts and FAQs.
- Griffin Bank (UK bank (full licence March 2024)). Offers: Safeguarding accounts, dedicated per end customer or one pooled account; general, designated client money and designated client fund accounts. Published conditions: For FCA-regulated EMIs and PIs; competitive interest advertised, rate not published; API; onboarding in days rather than months; FSCS protected; no minimums, fees or currency list published. Named payment firm clients: TransferGo (GBP wallets, May 2025); TransactPay (June 2025). Source: Safeguarding and account types.
- LHV Bank (UK bank (licensed May 2023)). Offers: Multicurrency safeguarding accounts for regulated entities; operational accounts; unlimited virtual IBANs. Published conditions: Regulated entities; GBP and EUR; instant IBAN issuance by API; onboarding asks for licences, jurisdiction and monthly volumes; interest, fees and FSCS position not stated. Named payment firm clients: B4B Payments (GBP and EUR safeguarding accounts, 2020). Source: Accounts.
- The Bank of London (UK bank). Offers: Safeguarding accounts built for EMIs and PIs; CASS, trust, general client funds and virtual accounts. Published conditions: FCA-compliant acknowledgement letter; deposits held in full at the Bank of England; Faster Payments to £1 million per transaction, Bacs to £20 million, CHAPS unlimited; will set up account structures for applicants before authorisation; no minimums, interest or currency list published. Named payment firm clients: None named. Source: Safeguarding and pre-regulated entities.
- Starling Bank (Banking Services) (UK bank). Offers: Client money accounts for e-money and payment institutions and investment firms; physical or virtual. Published conditions: Own addressable sort code; fully API based; Faster Payments access without direct scheme membership; no minimums, interest, currencies or eligibility published. Named payment firm clients: Earlier announcements name Vitesse, Instarem, Raisin UK and others, without describing them as safeguarding clients. Source: Banking Services.
- Banking Circle (UK branch of a Luxembourg bank). Offers: Safeguarded accounts and segregated client money accounts for regulated clients; virtual IBANs. Published conditions: Regulated financial institutions only; API, portal, SFTP and SWIFT; multi-currency, list not published; interest, fees and deposit protection not stated. Named payment firm clients: B4B Payments (2021). Source: Accounts.
- Barclays (Corporate) (UK bank). Offers: Safeguarding accounts referenced in its eligibility criteria for money service businesses; no product page. Published conditions: Fully authorised in every jurisdiction of activity under a regulator Barclays recognises; minimum revenue thresholds (figure not published) or fees to cover the gap; audited unqualified financials; new-to-bank questionnaire; independently reviewed financial crime controls report before onboarding and annually; signed safeguarding attestation at onboarding and each review; not all products guaranteed. Named payment firm clients: Wise Payments Ltd lists Barclays for cash deposits and secure liquid assets. Source: Eligibility criteria for MSBs.
- Crown Agents Bank (UK bank). Offers: Banking for payment service providers; a client describes fully safeguarded client accounts. Published conditions: Authorised or seeking authorisation by the FCA as a PSP; within the bank's risk appetite; business model, markets, management, controls and technology acceptable to the bank; not all products guaranteed; no minimums, fees or currencies published. Named payment firm clients: Sable International. Source: PSP solutions and PSP criteria (PDF).
Banks named by payment firms, with no public offer
Payment firms must tell customers where safeguarded money is held. Their disclosures name banks that do not advertise the service.
| Bank | Named by | What the disclosure says | Source |
|---|---|---|---|
| J.P. Morgan (JPMorgan Chase Bank, N.A. London; J.P. Morgan SE) | Wise Payments Ltd; Modulr Finance B.V. (EU entity); Payhawk | Wise lists JPMorgan Chase for cash deposits; Modulr's EU entity says it uses J.P. Morgan only for EU safeguarding; Payhawk announced J.P. Morgan Payments accounts for the safeguarding of funds (November 2024) | Wise, Modulr explanation (PDF), Payhawk |
| Citibank N.A., Deutsche Bank AG London, Bank of America N.A., Hamburg Commercial Bank | Wise Payments Ltd | Listed as cash deposit holders for safeguarded funds; Hamburg Commercial Bank sits under the approved foreign credit institution route | Wise |
| NatWest | MuchBetter | A May 2025 announcement says NatWest will provide fund safeguarding for MuchBetter's business accounts; no NatWest page exists | Announcement |
| Santander | PagoNxt (Santander group e-money entities) | Funds safeguarded at Santander banks or other credit institutions; a UK entity cannot use a same-group bank under regulation 23 | PagoNxt FAQs |
| Lloyds Bank | Not named by a payment firm | Publishes a Clients' Call Account for regulated business customers holding client money, aimed at solicitors and accountants, with acknowledgement letters on request; no mention of payment or e-money firms | Clients' Call Account (PDF) |
| HSBC UK, Metro Bank, Monzo, Allica, OakNorth, Cynergy, Zempler, GB Bank, Unity Trust, Weatherbys, Arbuthnot Latham, Hampden | Not named | Nothing published for payment or e-money firms | Bank of England list of banks, October 2026 |
Providers that are not banks
Several well-known providers of accounts to payment firms are themselves e-money institutions. Money held with them is not safeguarded under regulation 23; it is the provider's own safeguarding obligation that protects it, one step removed. Modulr says it uses a range of clearing banks without naming them; Currencycloud refers to reputable UK and EU banks; Equals Money to tier 1 banks; Tide's current accounts are provided by ClearBank. Clear Junction, also an e-money institution, distributes safeguarding accounts at Dukascopy Bank in Switzerland to UK and EU payment firms under the approved foreign credit institution route.
Two European banks sell safeguarding accounts to UK and EU payment firms directly: European Merchant Bank in Lithuania, which says any payment or e-money institution that passes its checks can open a safeguarding account and receive an acknowledgement letter, before the licence application if needed; and ClearBank Europe in the Netherlands, which has announced safeguarding arrangements with Fiat Republic and Bybit EU.
| Provider | Status | What it offers | Source |
|---|---|---|---|
| European Merchant Bank UAB | Lithuanian bank (ECB licence) | Safeguarding accounts for all PIs and EMIs that pass its checks; official acknowledgement letter; account can precede the licence application; fees and interest not published | Safeguarding accounts |
| Clear Junction with Dukascopy Bank | UK e-money institution distributing a Swiss bank's accounts | Safeguarding accounts at Dukascopy Bank for e-money and payment institutions (announced April 2023) | Announcement |
| Modulr, Currencycloud, Equals Money, Tide | UK e-money institutions | Accounts for businesses including payment firms; the money is safeguarded by the provider at banks it does not name | Modulr, Currencycloud, Equals, Tide |
What the FCA and the industry say about getting an account
The access problem is on the public record, in the regulator's own words and in the trade bodies' submissions.
| Date | Who | What they said | Source |
|---|---|---|---|
| 7 Aug 2025 | FCA, PS25/12 | Payment firms currently have difficulty getting these accounts; issues with accessing designated safeguarding accounts could potentially cause firms to exit the market. The statutory trust and direct receipt proposals were put back for further consultation; the diversification rules were kept without change. | PS25/12 (PDF) |
| 17 Dec 2024 | Electronic Money Association, response to CP24/20 | The acute difficulties payment firms face when seeking to access bank accounts; increased pressure on the already limited availability of safeguarding accounts in the UK; banks abroad refusing acknowledgement letters. | EMA response (PDF) |
| 25 Sep 2024 | FCA, CP24/20 | Some payment firms continue to experience difficulties accessing safeguarding accounts with credit institutions, attributed partly to the risk appetite of credit institutions; a lack of due diligence and acknowledgement of segregation from credit institutions listed among the common shortcomings. | CP24/20 (PDF) |
| 31 Jan 2024 | ClearBank and Celent | E-money institutions often struggle to find a banking partner that meets their needs and have limited choice in the safeguarding arrangements open to them; EMIs held £35 billion of customer deposits across Europe. | Report release |
| 19 Sep 2023 | FCA, UK payment accounts: access and closures | Credit institutions should not have policies that restrict access for certain categories of payments firms; some banks decline around 40% of business account applications; the significant majority of closures citing reputational risk were payments firms. | Report (PDF) |
| 4 Sep 2023 | Electronic Money Association, letter to the Governor of the Bank of England | Opening and maintaining safeguarding accounts remains a significant challenge; the number of banks with an appetite for offering safeguarding accounts is limited; even with established relationships, banks are reluctant to hold significant amounts of safeguarded funds. Asked the Bank to offer an interest-bearing safeguarding account. | EMA letter (PDF) |
| 16 Mar 2023 | FCA, payments portfolio letter | Firms must monitor their dependency on providers of critical services including banking, with contingency plans to move providers if necessary. | Letter (PDF) |
| 24 Jan 2023 | Griffin Bank | Opening a safeguarding account with a traditional bank can take up to six months or more; banks typically charge an upfront fee with no guarantee; most banks will not grant a safeguarding account unless the firm is already regulated. | Griffin blog |
| 9 Jul 2020 | FCA, temporary safeguarding guidance | A bank closing a safeguarding account is a notifiable event; an acknowledgement letter template; annual due diligence on the credit institution. | Guidance (PDF) |
| Jan 2015 and 2016 | Association of UK Payment Institutions | Around 150 authorised payment firms unable to operate at full capacity because they could not obtain banking facilities in their own name; the four main banks had closed 450 payment institution accounts; 92% of surveyed firms said banks failed to provide unhindered access. | Treasury Committee evidence and PSR submission (PDF) |
What the banks ask for
Read together, the published criteria describe the file a bank expects before it will open a safeguarding account. Barclays' list is the most explicit: authorisation in every jurisdiction where the firm operates, under a regulator the bank recognises; audited financial statements without qualification; a completed questionnaire on the firm's financial crime framework; an independently reviewed financial crime controls report before onboarding and every year after; and a signed safeguarding attestation at onboarding and at each periodic review. Crown Agents Bank adds that the business model, target markets, senior management experience, risk controls and technology must each fall within its risk appetite.
The newer banks ask for less paperwork up front but the same substance: ClearBank and Griffin restrict the accounts to firms holding the relevant FCA permission, LHV asks for licences held, jurisdictions and expected volumes, and The Bank of London will prepare account structures for an applicant that is not yet authorised. All of them will issue the acknowledgement letter in the FCA's form, which is the document the auditor and the FCA look for first.
Under CASS 15 the firm then owes the bank relationship a standing duty of its own: due diligence on the bank at least once a year, a reconciliation of the safeguarding account against the firm's records every business day, and a notification to the FCA if the bank gives notice to close. A firm that can show a bank a daily reconciliation and a clean acknowledgement letter file is a different proposition from one that cannot. For how the daily reconciliation works see the CASS 15 reconciliation guide.
Safeheld reconciles safeguarding accounts every business day for payment and e-money firms, works every difference to its cause and keeps the acknowledgement letters, due diligence and daily records the bank, the auditor and the FCA ask for. If your firm is opening or holding a safeguarding account, talk to us about safeguarding.
Frequently asked questions
Which UK banks offer safeguarding accounts to payment and e-money firms?
Six UK-authorised institutions publish an offer: ClearBank, Griffin Bank, LHV Bank, The Bank of London, Starling Bank's Banking Services arm and the UK branch of Banking Circle. Barclays and Crown Agents Bank publish eligibility criteria for payment firms without a product page. Payment firms' own disclosures also name J.P. Morgan, Citibank, Deutsche Bank, Bank of America and NatWest.
Can an e-money institution hold my safeguarded funds?
No. Regulation 23 of the Payment Services Regulations 2017 requires a safeguarding account to be at a credit institution authorised to accept deposits in the UK, or an approved foreign credit institution. An account at another e-money institution, or at a bank in the firm's own group, does not count.
What do banks charge for a safeguarding account?
No UK bank publishes fees, minimum balances or interest rates for safeguarding accounts. Barclays says it applies minimum revenue thresholds or charges fees to cover the gap; Griffin advertises competitive interest without stating a rate; Griffin has also said traditional banks typically charge an upfront fee with no guarantee of an account.
How long does it take to open a safeguarding account?
Griffin Bank has written that opening one with a traditional bank can take up to six months or more, and that most banks will not grant one until the firm is regulated. The newer banks advertise onboarding in days through their APIs, for firms that already hold the permission.
Does the FCA accept that safeguarding accounts are hard to get?
Yes. CP24/20 (September 2024) says some payment firms continue to experience difficulties accessing safeguarding accounts, and PS25/12 (August 2025) says firms currently have difficulty getting these accounts and that access issues could cause firms to exit the market. The FCA put its statutory trust and direct receipt proposals back for further consultation partly for that reason.
Can I use a European bank for a UK safeguarding account?
Yes, if it is an approved foreign credit institution supervised in an OECD country. European Merchant Bank in Lithuania and ClearBank Europe in the Netherlands sell safeguarding accounts to UK and EU payment firms, and Wise lists Hamburg Commercial Bank among its deposit holders.
How often is this page updated?
It is reviewed whenever a bank publishes, changes or withdraws a safeguarding offer for payment firms, or the FCA publishes on access to safeguarding accounts, and the review date at the top of the page is updated each time.
References
- Payment Services Regulations 2017, regulation 23
- Bank of England, list of banks, October 2026
- FCA, PS25/12 Changes to the safeguarding regime for payments and e-money firms
- FCA, CP24/20 Changes to the safeguarding regime for payments and e-money firms
- Electronic Money Association, letter to the Governor of the Bank of England, 4 September 2023
- Barclays Corporate, eligibility criteria for money service businesses
About Safeheld
Safeheld reconciles client money every day, resolves every difference and prepares every regulatory return for sign-off, for regulated firms in the United States, the United Kingdom, the European Union, Canada, Australia, Singapore and Hong Kong. To discuss your operations, contact us at safeheld.com/contact.
This tracker is compiled from public primary sources for general information and does not constitute legal or regulatory advice. Figures are as stated in the source documents and may be revised by the courts, the administrators or the FCA.